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MEMORANDUM

DATE:		February 11, 2010

SUBJECT:	Cost per Ton of HAP Reduced for Existing Stationary CI RICE

FROM:	Bradley Nelson and Tanya Parise, EC/R, Inc.

		

TO:		Melanie King, EPA OAQPS/SPPD/ESG

1.0	PURPOSE

The purpose of this memorandum is to present the cost per ton of
emissions reduced by applying controls to existing stationary
compression ignition (CI) reciprocating internal combustion engines
(RICE) less than or equal to 500 horsepower (HP) located at major
sources subject to National Emission Standards for Hazardous Air
Pollutants (NESHAP).  

2.0	INTRODUCTION

	EPA has extensively discussed the various exhaust aftertreatment
controls available to stationary CI engines in background documentation
for previous rulemakings.  The applicable add-on controls for stationary
CI engines include add-on control technologies based on oxidation and/or
reduction of pollutants.  The add-on control technologies discussed in
this memorandum are diesel oxidation catalysts (DOC) and open crankcase
ventilation (OCV)  

3.0	COST OF CONTROLS

The capital and annual cost of controls were developed using equipment
cost information obtained from control technology vendors and state
agencies and the estimation methodology outlined in the EPA Air
Pollution Control Cost Manual.  The development of the cost equations
for each of the applicable control technologies is presented in a
control cost memorandum.  EPA determined that the following cost
equations in Table 2 are representative of the applicable add-on
controls to be considered for stationary CI engines.

Table 2.  Summary of Capital and Annual Costs for Diesel HAP Control
Technology

Technology	Capital Cost ($2008)	Annual Cost ($2008)

DOC	$27.4 x HP - $939	$4.99 x HP + $480

OCV	$0.26 x HP + $997	$0.065 x HP + $254



4.0	EMISSION REDUCTIONS

	In order to estimate the baseline emissions of HAP, PM, volatile
organic compounds (VOC), and sulfur dioxide (SO2) from stationary
engines affected by this rulemaking, EPA obtained HAP emission factors
from the memorandum “Development of HAP Emission Factors for Small
(≤500 HP) Stationary Reciprocating Internal Combustion Engines
(RICE)” (EPA-HQ-OAR-2005-0030-0009).  Using the uncontrolled HAP
emission factors in conjunction with previously well-accepted
assumptions listed below, EPA estimated the uncontrolled HAP emissions
per year per subcategory.  EPA then estimated the emissions reductions
per engine subcategory.

Assumptions:

Stationary prime CI engines annual operation:		1,000 hrs/yr

Stationary emergency CI engines annual operation:		50 hrs/yr

Uncontrolled CI HAP emissions:				1.07 x 10-4 lb/HP-hr

Uncontrolled CI PM emissions:				7.00 x 10-4 lb/HP-hr

Uncontrolled CI VOC emissions:				2.47 x 10-3 lb/HP-hr

The cost per ton of HAP, PM, and VOC reduced for the DOC/OCV add-on
control technology options for emergency and non-emergency engines are
presented in Tables 3, 4, and 5.  Table 3.  Cost per ton ($/ton) of HAP
Reduced1 per Engine ($2008)

	< 50 HP	50–100 HP	100–175 HP	175-300 HP	300-500 HP	500-600 HP
600-750 HP	> 750 HP

CI Prime Engines 

(DOC + OCV)	$632,888	$380,463	$265,225	$207,583	$170,108	$162,459
$156,085	$146,969



CI Emergency Engines (DOC + OCV)	$17,706,275	$7,609,257	$5,304,503
$4,151,664	$3,402,166	$3,249,181	$3,121,693	$2,939,386

1 HAP reductions are estimated to be 70% based on the use of DOC and
OCV.

Table 4.  Cost per ton ($/ton) of PM Reduced1 per Engine ($2008)

	< 50 HP	50–100 HP	100–175 HP	175-300 HP	300-500 HP	500-600 HP
600-750 HP	> 750 HP

CI Prime Engines (DOC + OCV)	$225,730	$135,698	$94,597	$74,038	$60,672
$57,944	$55,670	$52,419

CI Emergency Engines (DOC + OCV)	$6,315,238	$2,713,968	$1,891,939
$1,480,760	$1,213,439	$1,158,874	$1,113,404	$1,048,381

1 PM reductions are estimated to be 30% based on the use of DOC and OCV.

Table 5.  Cost per ton ($/ton) of VOC Reduced1 per Engine ($2008)

	< 50 HP	50–100 HP	100–175 HP	175-300 HP	300-500 HP	500-600 HP
600-750 HP	> 750 HP

CI Prime Engines 

(DOC + OCV)	$27,417	$16,482	$11,490	$8,992	$7,369	$7,038	$6,762	$6,367

CI Emergency Engines (DOC + OCV)	$767,033	$329,632	$229,790	$179,849
$147,381	$140,754	$135,231	$127,334

1 VOC reductions are estimated to be 70% based on the use of DOC and
OCV.4.0	BENEFITS

The benefits per ton of PM and SO2 at 7 percent interest rate are shown
in Table 3.  For more information on the benefits per ton of pollutants
reduced and total monetized benefits, please refer to the “Regulatory
Impact Analysis (RIA) for Existing Stationary Compression Ignition
Engines NESHAP,” which can be found in the docket
(EPA-HQ-OAR-2008-0708). 

Table 3.  Summary of PM and SO2 Benefit per Ton for Existing Stationary
CI Engines 

Pollutant	Benefit per ton (Pope, 7%)	Benefit per ton (Laden, 7%)

	Major	Area	Major	Area

PM	$210,000	$330,000	$500,000	$790,000

SO2	$27,000	$18,000	$65,000	$44,000



 

 EPA Air Pollution Control Cost Manual Sixth Edition, January 2002,
EPA/452/B-02-001.

 Memorandum from Bradley Nelson, EC/R Inc., to Melanie King, EPA
OAQPS/SPPD/ESG, Control Costs for Existing Stationary CI RICE (see
EPA-HQ-OAR-2008-0708).

E C/R Incorporated	Providing Environmental Technical Support Since 1989



	

501 Eastowne Drive, Suite 325  (  Chapel Hill, North Carolina 27514

Telephone:  (919) 484-0222  (  Fax:  (919) 484-0122

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